This concise book is designed to provide professors teaching an introductory federal income taxation course with supplementary materials to introduce students to comparative and international tax topics. The book is accessible to students early in the course. An introductory chapter covers the structure of global tax systems and income taxes, as well as the various concepts of "income" employed by different tax systems. Coverage also includes chapters exploring the comparative tax treatment of in-kind benefits, gifts and inheritances, deductions, the taxable unit and income splitting rules, and capital gains. A separate chapter explores the issues raised when income is earned in international transactions. Basic international tax coverage includes an introduction to taxation based on source or residence/citizenship, avoidance of double taxation, tax deferral, transfer pricing, and tax treaties. The book includes both domestic and foreign cases, authorities, and statutes, as well as explanatory text. Because of its coverage, this text also is an excellent vehicle for exploring tax policy issues.

In 'Global Perspectives on Income Taxation Law', Avi-Yonah covers basic, corporate and international tax law from a comparative perspective. The book both supplements readings in U.S. tax law courses and serves as a textbook for a comparative tax law class.

This book presents 15 original papers and commentaries by a distinguished group of tax policy and tax administration experts. Using international examples, they highlight the state of knowledge of tax reform, present new thinking about the issue, and analyze useful policy options. The book’s general goal is to examine the current and emerging challenges facing tax reformers and to assess possible directions future reforms are likely to take. More specific themes include distributional issues, how to tax capital income, how to design specific taxes (e.g., the income tax, the value-added tax, the property tax), how to consider the politics and administrative aspects of tax reform, and how to combine the separate insights into comprehensive tax reform.

This volume presents philosophical contributions examining questions of the grounding and justification of taxation and different types of taxes such as inheritance, wealth, consumption or income tax in relation to justice and the concept of a just society. The chapters cover the different levels at which the discussion on taxation and justice takes place: On the principal level, chapters investigate the justification and grounding of taxation as such and the role taxation plays and should play in the design of justice, be it for a just society or a just world order. On a more concrete level, chapters present discussions of these general reflections in more depth and examine different types of taxation, tax systems and their design and implementation. On an applied level, chapters discuss certain specific taxes, such as wealth and inheritance taxes, and examine whether or not a certain tax should be favored and for what reasons as well as why it is just to target certain kinds of assets or income. Finally, this volume contains chapters that discuss the central issue of international and global taxation and their relation to global justice.

International taxation is evolving in response to globalization, capital mobility, and the increased trade in services, and introduces international tax practitioner, student and researcher to the theory, practice, and international examples of the changing landscape. Models of tax competition in a flat and connected world are very different than those necessary to ensure compliance in a world dominated by cross-border flows of goods and repatriation of profits. Taxes on consumption, e-commerce, and services are looming innovations in future of international taxation. Tax coordination and standardization are immense challenges in a world in which the movement of value is increasingly subtle and hard to detect. And as corporations and individuals become more sophisticated in the internationalization of flows of capital, our models must become more sophisticated in their scope and inclusion. In the era when trade was dominated by the exchange of manufactured goods, international taxation was designed to protect domestic industries, create tax revenue, prevent evasion, and promote compliance. The traditional toolbox of customs duties, tariffs, and taxes on repatriated profits must be augmented as the movement of goods across borders represents a much smaller fraction of trade and as international taxation policy is increasingly used to attract foreign corporations rather than discourage branch offices. International taxation models that can better tax services, track international flows of capital, and allow a nation to compete in a world market for capital formation are the tools of the modern tax practitioner. International tax policy is now viewed as an integral part of economic policy. This approach is bound to accelerate as the world becomes increasingly flat and better connected. Economic progress is more and more influenced by the movement of services and information, movements that are no longer through ports but through fiber optic lines. This book contributes to the growing literature on international taxation by bringing together theory and experience, current practices and innovation, and our current understanding of some of the challenges now facing and arguably frustrating current international taxation policy. The book will create new avenues of research for scholars, a new awareness for students of International Taxation, and new possibilities for international tax practitioners. The models and examples presented here suggest that there are serious problems with measurability of flows of services and information, and points to an increasingly need for greater harmonization of international taxation, perhaps through coordinated consumption-tax oriented approaches. * Describe the rapidly evolving role of International Taxation in a globalizing information economy * Present theoretical models that act as the basis for successful international tax competition * Describe the experiences and innovations of representative internationalized countries * Discuss some new approaches to International Taxation * Makes the case for new models of international taxation in an increasingly global information world

Income taxation is the fuel and vector of the economic policy of many states. This concise book, destined to students, practitioners and policy makers, explains the issues of taxation of transnational income in a world of sovereign states: how to prevent unjust and inefficient double taxation of the same income, by allocating the tax base between source and residence state and properly allowing in the latter for the tax levied in the former? How to prevent abuse by taxpayers or states, furthering tax evasion or avoidance and causing other but equally significant injustices and inefficiencies? Solutions developed over a century of practice are analyzed. That field of the legal art & science is still young and the paradigm for ideal taxation in the global village of the XXIst century is yet to be invented. An appendix includes the juxtalinear texts of the OECD and UN Model Conventions.

The increasing globalization of economic activity is bringing an awareness of the international consequences of tax policy. The move toward the common European market in 1992 raises the important question of how inefficiencies in the various tax systems—such as self-defeating tax competition among member nations—will be addressed. As barriers to trade and investment tumble, cross-national differences in tax structures may loom larger and create incentives for relocations of capital and labor; and efficient and equitable income tax systems are becoming more difficult to administer and enforce, particularly because of the growing importance of multinational enterprises. What will be the role of tax policy in this more integrated world economy? Assaf Razin and Joel Slemrod gathered experts from two traditionally distinct specialties, taxation and international economics, to lay the groundwork for understanding these issues, which will require the attention of scholars and policymakers for years to come. Contributors describe the basic provisions of the U.S. tax code with respect to international transactions, highlighting the changes contained in the U.S. Tax Reform Act of 1986; explore the ways that tax systems influence the decisions of multinationals; examine the effect of taxation on trade patterns and capital flows; and discuss the implications of the opening world economy for the design of optimal international tax policy. The papers will prove valuable not only to scholars and students, but to government economists and international tax lawyers as well.

The definitive book on the Fairtax and its potential to save the U.S. economy In the century since it was created, the federal income tax system has grown into a monster that threatens the well-being of average citizens and business owners as well as the very foundations of our economy and our democracy. But there's a better alternative: the FairTax. Its supporters argue that the federal government should stop taxing what goes into the economy-earnings, savings, and investments-and start taxing what comes out: consumption. The result would be the same amount of revenue but more growth, much less political corruption, and a far healthier relationship between Americans and their government. Ken Hoagland of the FairTax Institute is an expert on this grassroots movement, and his book offers the clearest explanation of this revolutionary idea. He details the history of income tax collection in this coun­try and current lobbying practices that have bloated the tax code to 67,500 pages of irrational regulations. Anyone who has ever shuddered as April 15 approaches or who simply cares about making the country better will be fascinated by Hoagland's research and conclusions.

The purpose of this book is to compare different solutions adopted by nine industrialized countries to common problems of income tax design. As in other legal domains, comparative study of income taxation can provide fresh perspectives from which to examine a particular national system. Increasing economic globalization also makes understanding foreign tax systems relevant to a growing set of transnational business transactions. Comparative study is, however, notoriously difficult. Full understanding of a foreign tax system may require mastery not only of a foreign language, but also of foreign business and legal cultures. It would be the work of a lifetime for a single individual to achieve that level of understanding of the nine income taxes compared in this volume. Suppose, however, that an international group of tax law professors, each expert in his own national system, were asked to describe how that system resolved specific problems of income tax design with respect to individuals, business organizations, and international transactions. Suppose further that the leaders of the group wove the resulting answers into a single continuous exposition, which was then reviewed and critiqued by a wider group of tax teachers. The resulting text would provide a convenient and comprehensive introduction to foreign approaches to income taxation for teachers, students, policy-makers and practitioners. That is the path followed by Hugh Ault and Brian Arnold and their collaborators in the development of this fascinating book. Henceforth, a reader interested in how other developed countries resolve such structural issues as the taxation of fringe benefits, the effect of unrealized appreciation at death, the classification of business entities, expatriation to avoid taxes, and so on, can turn to this volume for an initial answer. This book should greatly facilitate comparative analysis in teaching and writing about taxation in the US and elsewhere.